1 Naomi- Johnson Sui Juris Litigant

3 Date: July 16, 2025

4 Glen Ridge Municipal Court

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825 Bloomfield Avenue
Glen Ridge, NJ 07028
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7 )
Naomi Johnson )
8 ) MOTION TO VACATE AND QUASH
) BENCH WARRANT
9 Plaintiff )
)
10 )
) Municipal Court Docket No.:
11 vs. )
) Ticket Nos.: 0708 E25 000733 and
12 Glen Ridge Police Department, Sgt. ) 000734
Anthony Maza, and Public Officers )
13 )
)
14 Elizabeth Brewster, Esq. )
)
15 The Honorable Judge Mark Clemente

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Denise C. Iandolo Administrator,
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Violations Clerk
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Defendants
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COMES NOW, Naomi Johnson, a private woman, appearing specially and
not generally, without waiver and reserving all rights, to serve this formal
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Motion and Demand upon this Municipal Court and its public officers. This
22 Motion accompanies and supports the Affidavit of Fact and Demand to

23 Quash Warrant, and is based upon the following facts, legal presumptions,
and constitutional requirements:
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I. FACTUAL AND PROCEDURAL BACKGROUND
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1. Procedural Background
26 • On or about February 24, 2025, Naomi Johnson was issued two traffic
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28 MOTION TO VACATE AND QUASH BENCH WARRANT
 1 citations numbered 000733 and 000734 under N.J.S.A. 39:3-4 and
39:4-215 by Sgt. Anthony Maza of the Glen Ridge Police Department
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by Sgt. Anthony Maza of the Glen Ridge Police Department.
3 • The Noticed listed a court appearance date of April 8, 2025.
4 2. Timely and Lawful Response to Summons
5 • In accordance with N.J.S.A. 39:4-139.6, Respondent exercised her
statutory right to respond in writing to the summons and did so timely
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and lawfully.
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3. I am not a commercial driver, carrier, or licensee under the statutory
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definitions of N.J.S.A. Title 39, 49 CFR § 390.5, or N.J.A.C. 13:60. I do
9 not operate a business or enterprise involving transportation for hire. My
10 conveyance is private.
• On March 11, 2025, Respondent served by certified mail a package
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containing:
12 ◦ Motion to Dismiss,
13 ◦ Notice to Show Cause, and
◦ Notice of Default.
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• On April 1, 2025, prior to the scheduled court date, Respondent sent a
15 second certified mailing containing a Notice of Dismissal and supporting
16 documents.
17 • These filings were addressed to:
◦ Prosecutor Elizabeth Brewster,
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◦ Clerk Denise C. Landolo, and
19 ◦ With a courtesy c.c. request to submit to Hon. Mark Clemente for
20 review by the Judge Municipal Court (JMC), if applicable.
21 4. No Response or Acknowledgment by the Court
• Despite timely and lawful submissions, Respondent received no
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acknowledgment or ruling.
23 • The Court failed to docket or respond to these filings, effectively
24 depriving Respondent of due process, as required by the Fourteenth
25 Amendment of the U.S. Constitution and Article I, Paragraph 1 of the
New Jersey Constitution.
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28 MOTION TO VACATE AND QUASH BENCH WARRANT
 1 5. Notification of Bench Warrant
• On July 7, 2025, Respondent received an email from Lt. Timothy
2
Faranda informing her that a bench warrant had been issued.
3 • Respondent only became aware of this alleged warrant on July 15,
4 2025.
• The issuance of a warrant under these circumstances is improper and
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unlawful, given Respondent’s good faith, timely, and lawful compliance
6 with procedural requirements.
7 6. Misapplication of Law and Lack of Jurisdiction
8 • The underlying matter arises from alleged violations of motor vehicle
9 statutes, specifically under N.J.A.C. 13:60 and FMCSR regulations,
which apply solely to commercial motor vehicles.
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• Respondent does not own or operate a commercial motor vehicle, is
11 not engaged in commerce, and does not fall within the jurisdiction of
12 commercial transportation laws.
• Enforcement against Respondent under these commercial statutes
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constitutes a misapplication of law and a color of law violation.
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7. Legal Authority and Relief Requested
15 • Under Rule 7:6-2(c)(1) of the New Jersey Rules of Court, a defendant
16 may move to vacate a warrant if:
17 “The defendant was not properly notified or responded in a lawful
18 manner.”
• Pursuant to N.J.S.A. 39:4-139.6, filing a written response in lieu of a
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court appearance is permitted in many civil traffic matters. Respondent
20 complied fully.
21 8. Unlawful Seizure and Towing of Private Conveyance in Violation of
22 ADA
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• On or about February 24, 2025, Respondent’s privately owned
automobile—a red 1995 Ford Mustang used solely for private, non-
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commercial travel—was unlawfully seized and towed by order of Sgt.
25 Anthony Maza.
26 • The vehicle prominently displays a handicap license plate, clearly
identifying Respondent as a disabled person entitled to protections
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28 MOTION TO VACATE AND QUASH BENCH WARRANT
 1 under the Americans with Disabilities Act (ADA), 42 U.S.C. § 12132.
• Respondent was not engaged in any commercial activity nor subject to
2
enforcement under Title 39 commercial codes.
3 • The towing and impoundment were conducted without a warrant,
4 hearing, or adjudication, in direct violation of Respondent’s Fourth
Amendment rights and ADA Title II, which prohibits public entities from
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excluding or discriminating against individuals with disabilities.
6 • As a result, Respondent, suffering from known physical impairments,
7 was forced to walk home, experiencing physical distress, and
compelled to pay to retrieve her property (conveyance), which held
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groceries left to spoil for seven (7) days. This sitution had the
9 Respondent to incurring financial harm and confirming the abusive and
10 unlawful nature of the enforcement action. These facts demonstrate:
11  Willful disregard of her protected status,
12  Economic and emotional harm directly caused by public entity
13 misconduct.
14  N.J.S.A. 40:48-2.49, 40A:11-5(l)(u), and Glen Ridge Borough

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Ordinance 10.05 on impoundment.
II. DEMAND FOR QUASHING WARRANT AND DISMISSAL
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A. Lack of Jurisdiction
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This Court has not established subject matter jurisdiction over Respondent as
18 a private woman. There is no verified commercial activity, no signed contract,

19 and no evidence of damage, injury, or threat to public safety.

20 B. Violation of Due Process

Issuing a warrant without responding to the documents mention in this
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MOTION TO VACATE AND QUASH BENCH WARRANT or ruling on written
22 responses violates both the Fourteenth Amendment and applicable New

23 Jersey Court Rules.

24 C. Abuse of Police Power

25 The absent of judicial warrants for vehicle seizure in response to a disputed,
nonviolent civil traffic issue, especially where timely filings were submitted,
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constitutes abuse of process and enforcement under color of law.
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28 MOTION TO VACATE AND QUASH BENCH WARRANT
 1 D. Violation of Federal Disability Rights
Seizing the vehicle of a disabled person clearly marked with a handicap
2
license plate, forcing her to walk home, and causing financial injury violates
3 Title II of the ADA and constitutes unlawful discrimination by a public entity.

4 III. PRAYER FOR RELIEF

5 Wherefore, Respondent respectfully requests that this Honorable Court:

6 1. VACATE or QUASH the bench warrant allegedly issued in her name;

7 2. DISMISS both citations for lack of jurisdiction and procedural violations;
8 3. ACKNOWLEDGE the certified filings submitted on March 11 and April
9 1, 2025; as proper responses under N.J.S.A. 39:4-139.6;
10 4. REFRAIN from further adverse actions until the Court has adjudicated
the pending motions;
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5. RECOGNIZE the unlawful towing of Respondent’s conveyance and the
resulting ADA violations, and
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6. ORDER RESTITUTION for the impound fees incurred as a result of
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said unlawful seizure.
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IV. PRESERVATION OF RIGHTS
16 This Notice does not constitute consent to this Court’s jurisdiction. It is

17 submitted solely to assert Respondent’s rights and to demand lawful

adjudication under due process, constitutional guarantees, and statutory
18
protections including the Americans with Disabilities Act.
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Respectfully and lawfully submitted,
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22

23
Naomi Johnson, Private Woman

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25 Date: July 16, 2025

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28 MOTION TO VACATE AND QUASH BENCH WARRANT
 NOTARY ACKNOWLEDGMENT
1
State of New Jersey
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County of ____________
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On this ____ day of ________________, 2025, before me, the undersigned
4 notary public, personally appeared Naomi Johnson, known to me or

5 satisfactorily proven to be the person whose name is subscribed to this

document, and acknowledged that she executed the same for the purposes
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therein contained.
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In witness whereof, I hereunto set my hand and official seal.
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Notary Public Signature:
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My Commission Expires:
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28 MOTION TO VACATE AND QUASH BENCH WARRANT